Same-sex couples have been tying the knot in their thousands in the Netherlands for more than two years, but until now, if they travelled around the rest of Europe, suddenly their marriages were on shaky ground.

Gay couples in the Netherlands, who enjoy exactly the same rights as heterosexual couples - joint ownership of property, next of kin rights to pensions and inheritance - find when they travel or work elsewhere in Europe they are often denied those rights.

In addition, non-EU citizens have found themselves forced to stay behind when their other half moves country, because outside the Netherlands they are not considered spouses.

Denmark, France and Germany allow "civil unions" that provide many of the same rights as marriage but are easier to dissolve. But in more conservative countries like Italy and Greece, same-sex unions are still something of a taboo and no provision is made for couples arriving from the more liberal north.

This week, EU ministers endorsed a proposed set of rules ensuring that same-sex married couples from the Netherlands and Belgium - the only countries were such unions are legal - are recognized across the EU, by countries whose own gay and lesbian populations are still far from receiving the same recognition.

Under the new rules, which have yet to be made law by the EU parliament, gay and lesbian EU citizens and their families will be able to move freely around the EU and obtain permanent residence in any EU state once they have been resident there for at least five years.

"This is an important step," said Kees Waaldijk, a senior law lecturer at Leiden University and an expert in gay and lesbian rights. "Spouse cannot mean one thing in one EU country and another thing elsewhere."

He cited critical moments such as the death or injury of a partner, when police and medical services in some countries refuse to recognise a gay or lesbian spouse as next of kin. About 20,000 children are being raised by same-sex couples - mainly lesbians - in the Netherlands. They too face challenges to their parenthood when they leave the country.

COC, the Dutch federation of associations for the integration of homosexuality, published a manual on its 15-year struggle to legalise same-sex marriages recently. The booklet, No gay marriage in the Netherlands, is intended to show that there is no such thing as gay marriage because in the Netherlands the procedure and the rights are identical now for gay and heterosexual couples.

The book was seen as a guide and inspiration for gay and lesbian communities in the wake of a Vatican statement in July condemning legalisation of homosexual unions and urging Catholics to try to stop it.

"Marriage exists solely between a man and woman ... Marriage is holy, while homosexual acts go against the natural moral law," a 12-page document by the Vatican's congregation for the doctrine of the faith said.

"Legal recognition of homosexual unions or placing them on the same level as marriage would mean not only the approval of deviant behavior ... but would also obscure basic values which belong to the common inheritance of humanity."

While EU legislation may force all 15 member states to accommodate Dutch and Belgian ideas about marriage, the Dutch are already negotiating the next hurdle.

Over two years since gay marriage legislation was approved in the Netherlands, around 4,000 marriages have been registered but among those, the first divorces have begun to emerge.

"It is all part of normality. Just as many gay and lesbian marriages don't work out the way we hope they will at first," said Waaldijk.

When same-sex marriages were legalised in the Netherlands in 2001, he said, there was a bottle-neck of couples who had waited years to make their union official. Now, he said, many prefer to live together without getting married. Not everyone believes marriage is the best option.